Introduction - On February 25, 2026, the Office of the Comptroller of the Currency (the “OCC”) issued a Notice of Proposed Rulemaking (the “NPRM”) to implement the Guiding and Establishing National Innovation for U.S....more
2/27/2026
/ Banking Sector ,
Comment Period ,
Digital Assets ,
FinTech ,
New Legislation ,
OCC ,
Payment Systems ,
Proposed Rules ,
Regulatory Oversight ,
Regulatory Reform ,
Rulemaking Process ,
Stablecoins
In opening remarks at the Federal Reserve Bank of Atlanta’s 2026 Banking Outlook Conference, Federal Reserve Vice Chair for Supervision Michelle Bowman outlined what she described as “the next horizon in banking” — a...more
2/27/2026
/ Banking Sector ,
Basel III ,
Capital Requirements ,
Community Banks ,
Federal Reserve ,
Global Systemically Important Banks (G-SIBs) ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Reform ,
Risk Management ,
Stress Tests ,
Supervision
I. Introduction -
U.S. banks are increasingly turning to significant risk transfers (SRTs) to manage credit risk and optimize regulatory capital. SRTs are transactions that satisfy the definition and operational criteria...more
2/13/2026
/ Banking Sector ,
Banks ,
Capital Requirements ,
Contract Terms ,
Credit Default Swaps ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
Regulatory Requirements ,
Risk Management ,
Securitization
In remarks delivered on January 16, 2026, to the American Bar Association Banking Law Committee meeting in Washington, DC, Comptroller of the Currency Jonathan Gould offered a strong critique of the current U.S. bank...more
1/29/2026
/ American Bar Association (ABA) ,
Banking Regulators ,
Banking Sector ,
Banks ,
Depository Institutions ,
Dodd-Frank ,
FDIC ,
Financial Services Industry ,
OCC ,
Regulatory Oversight ,
Regulatory Reform ,
Regulatory Requirements ,
Rulemaking Process
On December 19, 2025, the Federal Reserve Board issued a Request for Information (“RFI”) on a proposed “Payment Account prototype.”...more
1/21/2026
/ Banks ,
Comment Period ,
Federal Reserve ,
Financial Services Industry ,
FinTech ,
Non-Depository Institutions ,
Payment Systems ,
Proposed Rules ,
Request For Information ,
Risk Mitigation ,
Rulemaking Process
On December 22, 2025, the Board of Governors of the Federal Reserve (the Board) issued a final rule that rescinded a 2023 policy statement and that in turn issued a new policy statement....more
1/21/2026
/ Banks ,
Consumer Financial Products ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
FinTech ,
Insured Depository Institutions ,
Investment ,
OCC ,
State Banks ,
The GENIUS Act
Overview:
On December 19, 2025, the Federal Reserve Board issued a Request for Information (“RFI”) on a proposed “Payment Account prototype.” The proposal responds to growing pressure from payments-focused institutions —...more
1/16/2026
/ Banking Sector ,
Comment Period ,
Federal Reserve ,
FinTech ,
Innovation ,
New Guidance ,
Payment Systems ,
Proposed Rules ,
Regulatory Oversight ,
Regulatory Reform ,
Request For Information ,
Risk Management
On December 16, 2025, the FDIC issued a notice of proposed rulemaking to implement the application and approval requirements under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”)...more
12/22/2025
/ Banking Sector ,
BSA/AML ,
Comment Period ,
Digital Assets ,
FDIC ,
Financial Services Industry ,
FinTech ,
Notice of Proposed Rulemaking (NOPR) ,
Payment Systems ,
Rulemaking Process ,
Stablecoins
On December 12, 2025, the Office of the Comptroller of the Currency (“OCC”) granted the conditional approval of five national trust bank charter applications involving crypto-focused institutions. The approvals include two de...more
On December 2, 2025 the House Financial Services Committee held an oversight hearing with leaders of the Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”), the National Credit Union Administration...more
12/9/2025
/ Banking Sector ,
Basel III ,
Capital Requirements ,
Congressional Oversight ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Services Committee ,
Financial Services Industry ,
NCUA ,
OCC ,
Stablecoins
Earlier this week, the Federal Reserve Board (“FRB”) issued a press release on changes in supervisory approach consistent with Vice Chair of Supervision Michelle Bowman’s priorities, which she articulated in, among other...more
On November 5, 2025, the Federal Reserve Board (“FRB”) finalized changes to its supervisory rating framework for large bank holding companies. The finalized LFI framework is substantially similar to the proposal issued in...more
Last week, on October 7, 2025, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued two joint notices of proposed rulemaking (NPRs)....more
10/16/2025
/ Banking Sector ,
Comment Period ,
FDIC ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Proposed Rules ,
Regulatory Agencies ,
Regulatory Oversight ,
Regulatory Reform ,
Reputational Injury ,
Risk Management ,
Rulemaking Process
As we previously reported, on August 29, the Federal Reserve Board (“FRB”) announced the individual capital requirements for all large banks, effective on October 1. This announcement follows the June announcement on the...more
On September 8, 2025, the Office of the Comptroller of the Currency (“OCC”) released a press release and two bulletins aimed at curbing so-called debanking activities, and reminding banks of their obligations to protect...more
On August 29, the Federal Reserve Board (“FRB”) announced the individual capital requirements for all large banks, effective on October 1. This announcement follows the June announcement on the results of the supervisory...more
Last week, (almost two years to the day of when it was issued), the Federal Reserve Board (“FRB”) rescinded SR Letter 23-7 regarding the creation of the Novel Activities Supervision Program. The FRB stated that supervision of...more
8/21/2025
/ Banking Regulators ,
Banking Sector ,
Blockchain ,
Cryptocurrency ,
Digital Assets ,
Federal Reserve ,
Financial Institutions ,
FinTech ,
Innovative Technology ,
Regulatory Oversight ,
Regulatory Reform
Introduction The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” or the “Act”) establishes a legal framework for defining, issuing, custodying and managing a specific kind of...more
Last week, the Federal Deposit Insurance Corporation (“FDIC), Federal Reserve Board (“FRB”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “the Agencies”) issued a proposed rulemaking to both...more
On July 22nd, the Federal Reserve Board (“FRB”) hosted the Integrated Review of the Capital Framework for Large Banks Conference. The Conference appears to be a first of its kind for the FRB, and as Chair Jay Powell noted in...more
On June 27, the Federal Reserve Board issued the aggregate and individual results of the supervisory stress test (also known as the Dodd-Frank Act Stress Test or DFAST, as these tests are required by Section 165 of the...more
This week, the Federal Reserve Board (“FRB") and the Office of the Comptroller of the Currency (“OCC”) issued a notice of proposed rulemaking (“NPR") to amend the Enhanced Supplementary Leverage Ratio (“eSLR”). At the time of...more
The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more
6/24/2025
/ Cryptocurrency ,
Digital Assets ,
Digital Currency ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment ,
OCC ,
Payment Systems ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Service Professionals ,
Stablecoins ,
U.S. Treasury
In response to a request from the Conference of State Bank Supervisors (“CSBS”), Acting Comptroller of the Currency, Rodney E. Hood, decisively defended OCC regulations regarding the ability of national banks and Federal...more
Last Friday, following her confirmation by the Senate as Federal Reserve Board Vice Chair of Supervision, Michelle Bowman laid out some of her priorities in a speech entitled “Taking a Fresh Look at Supervision and...more